AO 91 (Rev. 11/11) Criminal Complaint AUSAs Barry Jonas (312) 886-8027 and Raj Laud (414) 469-6306 UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF ILLINOIS EASTERN DIVISION UNITED STATES OF AMERICA CASE NUMBER: v. UNDER SEAL JOSEPH D. JONES and EDWARD SCHIMENTI CRIMINAL COMPLAINT I, the complainant in this case, state that the following is true to the best of my knowledge and belief. From at least on or about February 24, 2017, until at least on or about April 7, 2017, in the Northern District of Illinois, Eastern Division, the defendants violated: Code Section Offense Description Title 18, United States Code, conspiring and attempting to provide material 2339B(a)(1) support and resources, namely, personnel and equipment, to a foreign terrorist organization, namely, the Islamic State of Iraq and al Sham, knowing that the organization was a designated terrorist organization, and that the organization had engaged in and was engaging in terrorist activity and terrorism This criminal complaint is based upon these facts: X Continued on the attached sheet. CASSANDRA B. CARNRIGHT Special Agent, Federal Bureau of Investigation (FBI) Sworn to before me and signed in my presence. Date: April 11, 2017 Judge’s signature City and state: Chicago, Illinois M. David Weisman, U.S. Magistrate Judge Printed name and Title UNITED STATES DISTRICT COURT ) ) NORTHERN DISTRICT OF ILLINOIS ) AFFIDAVIT I, Cassandra B. Carnright, being duly sworn, state as follows: 1. I am a Special Agent with the Federal Bureau of Investigation. I have been so employed since approximately March 2016. 2. As part of my duties as an FBI Special Agent, I investigate criminal violations relating to international terrorism, including providing and conspiring, and attempting to provide, material support or resources to foreign terrorist organizations, in violation of Title 18, United States Code, Section 2339B(a)(1). As a result of my training and experience, to include information provided by other federal agents with applicable knowledge, I am familiar with the tactics, methods, and techniques used by terrorist networks and their members. In addition, I have participated in the execution of multiple federal search warrants. 3. This affidavit is made in support of a criminal complaint alleging that JOSEPH D. JONES, a/k/a “Yusuf Abdulhaqq,” and EDWARD SCHIMENTI, a/k/a “Abdul Wali,” have violated Title 18, United States Code, Section 2339B(a)(1). 4. This affidavit is also submitted in support of an application for a warrant to search a single family home located at [redacted] in Zion, Illinois (Subject Premises). 5. This affidavit is also submitted in support of a warrant to search the following electronic devices: a. A black Samsung cellular phone, assigned telephone number (773) 699-XXXX and used by JONES (Subject Phone 1). b. A black LG cellular phone, assigned telephone number (224) 430- XXXX and used by SCHIMENTI (Subject Phone 2). c. Because this affidavit is submitted for the limited purpose of establishing probable cause in support of securing search warrants and for a criminal complaint charging JONES and SCHIMENTI with conspiring and attempting to provide material support and resources, namely, personnel and equipment, to a foreign terrorist organization, namely, the Islamic State of Iraq and al-Sham (ISIS), knowing that the organization was a designated terrorist organization, and that the organization had engaged in and was engaging in terrorist activity and terrorism, I have not included each and every fact known to me concerning this investigation. I have set forth only the facts that I believe are necessary to establish probable cause to believe that the defendants committed the offense alleged in the complaint, and that evidence of this offense will be found at or within the places and items to be searched. 6. At various points in the Affidavit, I offer my interpretations of certain communications in brackets and otherwise. These interpretations, which include translations of certain words and phrases in the Arabic language, are based on my knowledge of the investigation to date and review of prior communications, the contents and context of the communications, prior and subsequent communications, 2 conversations with other law enforcement officers and agents, conversations with one or more Arabic translators employed by the FBI, and my experience and familiarity with terrorist organizations generally. Some of these summaries do not include references to all the topics covered during the course of the communications. In addition, the summaries do not necessarily include references to all statements made by the speakers on the topics that are mentioned. Finally, quotations from written communications are as they appear in their original form, including any grammatical or spelling errors. Although transcribers have attempted to transcribe the communications accurately, to the extent that quotations from these communications are included, these are preliminary, not final, transcriptions. OVERVIEW 7. As described in more detail below, JONES and SCHIMENTI have conspired and attempted to provide material support and resources, namely, personnel and cellular telephones, to a designated foreign terrorist organization, namely, ISIS. Specifically, JONES and SCHIMENTI each provided cellular telephones to an individual whom, unbeknownst to JONES and SCHIMENTI, was an FBI Confidential Human Source (the CHS).1 JONES and SCHIMENTI provided these cellular telephones to the CHS with the belief and understanding that they would be transported by the CHS to ISIS-controlled territory and provided to ISIS for use in assembling improvised explosive devices (IEDs) to conduct violent attacks. 1 To date, the CHS has been paid approximately $14,855 by the FBI. All of the payments, with the exception of approximately $500, were used to cover investigation related expense. 3 8. In addition, JONES and SCHIMENTI worked together to prepare and support the CHS’s purported travel overseas to fight on the behalf of ISIS. Specifically, SCHIMENTI expressed support for the CHS’s plans to travel to fight on behalf of ISIS, helped the CHS improve his physical fitness so he would be prepared to fight with ISIS, counseled the CHS to be cautious to avoid detection by law enforcement, and introduced the CHS to JONES, for the purpose of JONES introducing the CHS to a purported ISIS facilitator who would assist the CHS with joining ISIS. JONES, in turn introduced the CHS to an individual whom JONES believed operated an ISIS facilitation network capable of delivering the CHS to ISIS- controlled territory in Syria. The Islamic State of Iraq and al-Sham 9. On October 15, 2004, the United States Secretary of State designated al-Qa’ida in Iraq (AQI), then known as Jam’at al Tawhid wa’al-Jihad, as a Foreign Terrorist Organization (FTO) under Section 219 of the Immigration and Nationality Act and as a Specially Designated Global Terrorist under section 1(b) of Executive Order 13224. 10. On May 15, 2014, the Secretary of State amended the designation of AQI as a FTO under Section 219 of the Immigration and Nationality Act and as a Specially Designated Global Terrorist entity under section 1(b) of Executive Order 13224 to add the alias Islamic State of Iraq and the Levant (ISIL) as its primary name. The Secretary also added the following aliases to the FTO listing: The Islamic State of 4 Iraq and al-Sham (“ISIS” – which is how the FTO will be referenced herein), the Islamic State of Iraq and Syria, ad-Dawla al-Islamiyya fi al-Iraq wa-sh-Sham, Daesh, Dawla al Islamiya, and Al-Furquan Establishment for Media Production. On September 21, 2015, the Secretary added the following aliases to the FTO listing: Islamic State, ISIL, and ISIS. To date, ISIS remains a designated FTO. 11. Based on my training and experience: (a) Sunni extremists and others, who are not citizens or residents of Syria and Iraq, have been traveling to Syria and Iraq to join ISIS and commonly enter Syria by crossing the border from Turkey; (b) Abu Bakr al-Baghdadi is the current leader of ISIS and is frequently referred to as “Khalifa” or “Khalifa Abu Bakr al-Baghdadi”; (c) the terms “dowlah,” “dawlah,” “dowla,” and “dawla” are Arabic terms that mean country or state and are commonly used to refer to ISIS, which is also known as “the State;” and (d) ISIS maintains a flag with a black background and white letters, written in Arabic on the top, translated to “There is no God but Allah.” In the middle of the flag is a white circle containing black lettering translated to, “Mohammed is the Messenger of Allah”. JOSEPH D. JONES 12. According to State of Illinois identification records, JONES is a 35-year- old, who resides at [redacted] in Zion, Illinois (Subject Premises). Based on surveillance, law enforcement agents familiar with the physical appearance of JONES have observed him at the Subject Premises on numerous occasions. More specifically, agents have observed JONES present at the Subject Premises on or 5 about June 16, 2016, December 13, 2016, and March 26, 2017. Additionally, following a meeting between an FBI undercover employee (UC1) and JONES, UC1 dropped JONES off at the Subject Premises. Similarly, the CHS observed JONES at the Subject Premises on or about February 24, 2017 and March 26, 2017. EDWARD SCHIMENTI 13. According to Illinois driver’s license records, SCHIMENTI is a 35-year- old who resides in Zion, Illinois. PROBABLE CAUSE IN SUPPORT OF CRIMINAL COMPLAINT AND SEARCH WARRANTS 14. As set forth in more detail below, law enforcement is conducting an investigation of JONES and SCHIMENTI’s conspiracy to provide material support and resources to ISIS. In approximately September 2015, JONES was introduced to an FBI undercover employee, UC1, who informed JONES that he was preparing to travel to the Middle East to join ISIS with the assistance of a purported ISIS facilitator.